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Category: IP CAH

COVID-19 Accelerated Payments

CMS has expanded cash advances for most hospitals. Have you calculated your payment?
Updated 4/28/2020:
Please find a link to the CMs table that shows a State by State breakout of the accelerated payments as of Friday, April 24, 2020. CMS indicates they plan to update this information once a week on their website.

Updated 4/27/2020: 

Beginning on April 26, 2020, CMS will not be accepting any new applications for the Advance Payment Program, and CMS will be reevaluating all pending and new applications for Accelerated Payments.

Updated 4/8/2020 from original 3/30/2020 article:
CMS stated that they will prioritize the accelerated payments for states that were hit the hardest (CA, NY and WA).
In a little over a week, CMS has already authorized $34B in accelerated payments to providers, approving over 17,000 requests so far out of 25,000 received.  Prior to COVID-19, CMS has approved only 100 total requests for accelerated payments in the past five years, with most being tied to natural disasters such as hurricanes.
Expansion of Accelerated Payments
In order to increase cash flow to providers impacted by COVID-19, CMS has expanded the current Accelerated and Advance Payment Program to a broader group of providers for the duration of the public health emergency.
Who is Eligible?
To qualify for accelerated payments, the provider/supplier must:
  • Have billed Medicare for claims within the last 180 days;
  • Not be in bankruptcy;
  • Not be under medical review or program integrity investigation; AND
  • Not have any outstanding delinquent Medicare overpayments
How Much Will You Receive?
Most hospitals may receive up to 100% of their Medicare payment for a 6-month period. CAHs may receive up to 125% over that same period. All other providers may receive up to 100% for a 3-month period of Medicare payments.
How Does the Process Work?
Providers that meet the qualifications must submit the appropriate forms as designated by each MAC on their respective websites. The MACs will review and issue payments within seven calendar days of receipt. Repayment must begin 120 days after the date of issuance of the payment, via withholding of future claim payments. Most hospitals will have one year from the date the accelerated payment was received to repay the balance.
For further information, please refer to the complete CMS guidance here.
Toyon’s Take:
Providers will need to review their individual MAC’s website in order to access the appropriate forms and procedures. Providers should also estimate their Medicare payments over the applicable period based on the most current data available, in order to verify the amount calculated by the MAC.
If you need assistance with that calculation, you may find the attached template helpful. Alternatively, if it is administratively easy for your organization to do, you may also want to consider generating a report from your hospital billing system that will show payments received over the applicable period up through March 30, 2020. It is our understanding that CMS may be requesting that the MACs generate a report of actual payments out of HIGLAS for the applicable period, which would match this data source.
Please contact Robert Howey at or 888.514.9312 with any questions or for assistance calculating your expected payment.
Toyon Associates, Inc.

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Revisions to State Operations Manual (SOM), Appendix W for CAHs

From: CMS Transmittal 138 (Pub. 100-07) – 4/7/15

Summary of Changes:

Appendix W, Survey Protocol, Regulations and Interpretive Guidance for Critical Access Hospitals (CAHs) and Swing Beds in CAHs, is being revised to reflect recent regulation changes.  We are also taking this opportunity to make clarifications and updates to existing guidance.

Read more: Revisions to State Operations Manual (SOM), Appendix W for CAHs

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Lawmakers take a stand for Rural Hospitals

From: AHA News – 2/6/15

Article Excerpt:

A bipartisan group of lawmakers have recently introduced a spate of AHA-backed legislation that supports small and rural prospective payment system (PPS) hospitals and critical access hospitals (CAH).  Securing passage of the legislation is part of the AHA’s advocacy agenda. The rural hospital relief bills include the following.

 Making MDH program, low-volume adjustment permanent.Sens. Charles Grassley, R-Iowa, and Chuck Schumer, D-N.Y., joined Reps. Tom Reed, R-N.Y., and Peter Welch, D-Vt., on Feb. 3 to introduce the Rural Hospital Access Act, S. 332/H.R. 663, legislation that would make permanent both the Medicare-dependent Hospital (MDH) program and the enhanced low-volume Medicare adjustment for small rural PPS hospitals.

Without congressional action, the current short-term extension of the programs will expire on March 31. In letters of support for the legislation, AHA Executive Vice President Rick Pollack called these “vital programs for America’s rural hospitals and the patients and communities they serve.”

Under the MDH program, about 200 hospitals that are more dependent on Medicare revenue because of the high percentage of Medicare beneficiaries in rural areas receive the sum of their PPS payment rate, plus three-quarters of the amount by which their cost per discharge exceeds the PPS rate. The enhanced low-volume adjustment helps level the playing field for hospitals in small and isolated communities, which frequently cannot achieve the economies of scale possible for their larger counterparts.

Extending the Rural Community Hospital Demonstration. Rep. Don Young, R-Alaska, introduced on Feb. 3 the Rural Community Hospital Demonstration (RCH) Extension Act, H.R. 672, which would extend the demonstration for five years.

The program enables rural hospitals with fewer than 51 acute-care beds to test the feasibility of cost-based reimbursement. Currently, 23 small rural hospitals participate.

“By extending the demonstration for five more years, your legislation will ensure that RCH continues to help America’s communities in many ways, especially by allowing hospitals to expand and improve the services rural communities need,” the AHA’s Pollack wrote the bill’s sponsor in a letter of support. The program was created by the 2003 Medicare Modernization Act of 2003 and extended by the Affordable Care Act.

Removing 96-hour certification requirement for CAHs. Sens. Pat Roberts, R-Kan., and Jon Tester, D-Mont., Jan. 27 introduced a Senate companion to the Critical Access Hospital Relief Act, S. 258/H.R. 169. The legislation would remove the 96-hour physician certification requirement as a condition of payment for CAHs.

Medicare currently requires physicians to certify that patients admitted to a CAH will be discharged or transferred to another hospital within 96 hours in order for the CAH to receive payment under Medicare Part A.

The Centers for Medicare & Medicaid Services (CMS) has not historically enforced the requirement, but in recent guidance related to its two-midnight admissions policy implied that it will, a situation that would threaten patients’ access to longer care when needed. The legislation would not remove the requirement that CAHs maintain an average annual length of stay of 96 hours, nor affect other certification requirements for hospitals.

“This absurd rule puts arbitrary limits on how many hours patients can stay in critical access hospitals, and asks doctors to be clairvoyant and predict the unknown when admitting a patient,” said Roberts, who is co-chairman of the Senate Rural Health Caucus.

Original co-sponsors include Sens. John Thune, R-S.D., Jerry Moran, R-Kan., John Barrasso, R-Wyo., Daniel Coats, R-Ind., Grassley, Thad Cochran, R-Miss., Deb Fischer R-Neb., Steve Daines, R-Mont., James Inhofe, R-Okla., Roger Wicker, R-Miss., John Hoeven, R-N.D., Heidi Heitkamp, D-N.D., and Tammy Baldwin, D-Wis.

The AHA’s Pollack wrote the bill’s sponsors that the measure would “provide important relief for (critical access hospitals) and help ensure all Americans – no matter where they live – have access to essential health care services.”

Read more…

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